The URL can be used to link to this page

Home My WebLink About07-0496 . Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JOHN METRO CREMO, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW CAROLE J. CREMO, Defendant 07 - 4ft, CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed against you and a decree in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation with your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 BY tlrew C. Sheel PA. I.O. No. 624 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JOHN METRO CREMO, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. . . CIVIL ACTION - LAW CAROLE J. CREMO, Defendant 07 _ 'I9t, CIVIL TERM . . : IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is JOHN METRO CREMO, an adult individual who Cumberland County, Pennsylvania. currently resides at 8 Cicada Drive, Mechanicsburg, Pennsylvania, 2. Defendant is CAROLE J. CREMO, an adult individual who resides at 808 North Market Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 4, 1982 in Morristown, New Jersey. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to in counseling. request that the court require the parties hereto to participate 8. The marriage between the parties is irretrievably broken. 9. Plaintiff avers that he is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render his condition intolerable, life burdensome, unhealthy and impossible for a meaningful relationship or reconciliation. 10. This divorce action is not collusive. 11. The parties separated on or about December 30, 2006. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. COUNT II. CLAIM FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY URDER SECTION 3502 OF THE DIVORCE CODE 12. The allegations in Paragraphs 1 through and including 10 are incorporated herein and made a part hereof. 13. Plaintiff and Defendant are the owners of various personal property, motor vehicles, bank accounts, retirement accounts, retirement assets and insurance policies acquired during their marriage. 14. Plaintiff and Defendant are the owners of real property acquired during their marriage. 15. Plaintiff and Defendant have acquired various marital debt during the period of their marriage. 2 distribute the parties marital property, including marital debt, WHEREFORE, Plaintiff requests your Honorable Court equitably and including any such further relief as the Court may determine equitable and just. rew C. Sheely, Attorney for PIa' PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 Date: January If ' 2007 3 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. John Met ~~ Date: January ~ , 2007 . . Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JOHN METRO CREMO, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW CAROLE J. CREMO, Defendant : 07 - ;19(, CIVIL TERM . . IN DIVORCE AFFIDAVIT John Metro Cremo, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn " r- falsification to authorities. (\ 1 i ~ ~ "- ~ ~~ ~.~ ~ ~. ~ ~ \~ IS ~ ) .....~ ~ ~ \ ~, ~l~ \~ ~ ~ '-.I V-J "t) '\\ ~. ~ 0 '" = 0 c:: = ." -:.. -... ...~ '- :r!:n )- ~ n 1 i=- N -'("", f"Tl ,J::- :0 C? '-10 ~ ~~ tf~ -- .......""" C5 "-j -i:"" ::r:-~ :::0 ~ ""< '- . tit.. Andrew C. Sheely, Esquire 127 S. Market street P.O. Box 95 Mechanicsburg, PA 17055 FA 1D NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JOHN METRO CREMO, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : CIVIL ACTION - LAW : CAROLE J. CREMO, Defendant 07 - 496 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA . . : SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon CAROLE J. CREMO, Defendant, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt card, n January 25, 2007. SWORN to and subscribed before me this~q day of January, 2007. ~ C# ' ;?-; ( f>Jr7-{ Nota Public .' NOTARIAL SEAL ' BECKY M. KNISelY, N.-, Public ~Boro, ~ndCo. .., COmm .'DO &phs Now. 19, 2010 My commission Expires: o c:. s: -r)o: rrlP' ~--€: (J) .1": '-< ---- ~c 1?:(": :.so >c: -~.... ~ -<. ~ <::::) --J -r'\ ~ ~ ~:!:l a; ~~. ~~ 9. - ~ -0 ::l' tit Q"I , T T . Complete Items 1, 2, and 3. Also complete item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: Carole J. Cremo RESTRICTED DELIVERY ADDRESSEE ONLY 808 North Market Street Mechanicsburg, PA 17055 2. Article Number (Copy from service label) D. Is . ry address different from item 1? If YES, enter delivery address below: 3. Service Type " Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise "'-' 0 Insured Mail 0 C.O.D. 14. Restricted Delivery? (Extra Fee) }i1Yes 7001 2510 0000 3029 2233 102595-00-M-0952 PS Form 3811 , July 1999 Domestic Return Receipt fT1 fT1 ru ru a- ru CJ fT1 Certified Fee Return Receipt Fee g (Endorsement Required) CJ Restricted Delivery Fee CJ (Endorsement Required) o M LI1 ru Totel Postage &. F... $ M o CJ t'- \fo.. " ~ II .. ,. 8 ", c:::' <:) c:::' -o~ -; -Tl -r, :I! m..r, ,....; c.; n" ;::2 -cr Eg 0'\ -'J . (.')6 .-1 \:1 --r: ., .....~.. ~-n -""- '5 (".) om ~ en < ..... ..J ..... If ~ 1 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) andrewc.sheely@verizon.net JOHN METRO CREMO, Plaintiff v. CAROLE J. CREMO, Defendant ~` ~~'~` P~'Q7`F~t7~~~ v ~~~~; polo ocr ~ ~ PN 3; s ~~ pE~1~•'S y~D CdUI~TY MANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 07-496 CIVIL ACTION-LAW DIVORCE PRAECIPE TO WITHDRAW AND DISCONTINUE DIVORCE ACTION TO: DAVID D. BUELL, PROTHONOTARY Kindly withdraw and discontinue the divorce action filed on behalf of the Plaintiff in the above-captioned matter. Respe~fully submitted, October 1, 2010 By: Arld~`ew C. Sheely, Es u' Pa. ID No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050 Attorney for Plaintiff 4 CERTIFICATE OF SERVICE I, Andrew C. Sheely, Esquire, hereby certify that I am this day serving the foregoing Praecipe to Withdraw and Discontinue the Divorce Action upon the following named individual this day by depositing same in the United States Mail, First Class, postage prepaid, at Mechanicsburg, Pennsylvania, addressed as follows: Stanley J. A. Laskowski, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 Date: October ~ 2010 Andrew C. Sheely, Esquire